Flawed EPA Approach Threatens Formaldehyde Access for Key U.S. Industries
Access to a proven “building-block” chemical that consumers extensively rely on and powers some of the largest sectors of the economy is under threat due to scientifically unjustified over-regulation. The building block is formaldehyde, which is a naturally occurring substance made simply of carbon, hydrogen and oxygen.
Due to its usefulness, formaldehyde is already one of the most well-studied, well-understood compounds in commerce. Federal agencies, including the Food and Drug Administration, the Occupational Safety and Health Administration, the Department of Housing and Urban Development, the Consumer Product Safety Commission, and agencies across the World, all agree that formaldehyde is safe for use in a variety of applications.
Maintaining access to this vital chemistry is critical for agriculture, building and construction, automobile manufacturing and healthcare sectors, as well as the nation's manufacturing capability, economic viability, health, safety and continuity of essential products and services. Unfortunately, the U.S. Environmental Protection Agency (EPA) is pursuing a rushed formaldehyde assessment and biased scientific review process that could upend economic progress and threaten public health.
What is formaldehyde?
All life forms — bacteria, plants, fish, animals and humans — naturally produce formaldehyde as part of normal metabolic functions. The human body produces approximately 1.5 ounces of formaldehyde per day as part of cell metabolism. It is naturally present in the environment and found in a wide variety of fruits, vegetables, meats, fish and beverages.
Formaldehyde does not accumulate in humans or the environment, plants or animals. Studies show that formaldehyde is quickly broken down by natural metabolic processes in the body, converted to carbon dioxide and exhaled. In the environment, formaldehyde is rapidly broken down in the air by moisture and sunlight or by bacteria in soil or water.
While formaldehyde is best known for its preservative and anti-bacterial properties critical for agriculture, formaldehyde-based chemistry is also used for a wide range of products in the building and construction, healthcare, and automotive sectors. Due to its usefulness, formaldehyde is one of the most well-studied, well-understood compounds in commerce.
How does formaldehyde benefit key industries and society?
Formaldehyde is an essential chemical building block for products that improve everyday life, but little if any formaldehyde generally remains in the final products consumers use. Here are just some of its applications.
Agriculture: Formaldehyde helps families access safe and less expensive food products. It also helps protect livestock against diseases capable of causing catastrophic economic losses for farming operations nationwide. Federal agencies oversee the safe use of formaldehyde in agriculture applications.
- Veterinarians depend on formaldehyde products to disinfect and sterilize their facilities as well as for laboratory preservation.
- Pork farmers use formaldehyde to reduce virus infectivity and to protect against Salmonella. Research suggests formaldehyde could be used for effective risk mitigation against African Swine Fever, one of the most dangerous pig diseases.
- Crop producers utilize formaldehyde-based products to increase crop yields, helping to optimize agricultural production worldwide while reducing runoff, nutrient pollution, and species loss.
- Poultry producers rely on formaldehyde to protect against bacteria and viruses, including Salmonella, E. coli and staph.
- Egg producers use formaldehyde to help protect hatching eggs against bacteria like Salmonella which can cause poor chick quality and growth, costing farmers millions of dollars.
- Animal feed can become contaminated with bacteria capable of causing diseases. Formaldehyde-based feed additives fight bacteria, improving healthy end-products for consumers and safe operations for animals and farm workers.
- Aquaculture relies on formaldehyde to help control fungi in egg hatcheries and to treat deadly infections like Columnaris disease, which impacts many fish varieties. As a water additive, formaldehyde helps kill parasites that impact finfish and shrimp.
Housing Affordability: Unworkable regulations for formaldehyde products could result in significant increases in the costs of building new homes and multi-family housing. Formaldehyde-based resins are used to manufacture composite and engineered wood products for cabinetry, countertops, moldings, furniture, shelving, stair systems, flooring, wall sheathing, support beams and trusses, furnishings and structures. Glues using formaldehyde as a building block are exceptional bonding agents, delivering high-quality, economic performance. Wood products rely on formaldehyde-based resins for a wide range of panel and board products, enabling sustainable use of forestry resources and minimizing waste. For example, composite wood panels are typically made from recovered wood waste that might otherwise be burned or disposed of in landfills. In addition, these formaldehyde resins facilitate the storage of large amounts of carbon in long-lived wood product, making them climate change mitigating rock stars (wood is 50% carbon).
Automobile/aerospace applications: Formaldehyde technology helps make vehicles lighter and more energy efficient. Formaldehyde-based resins are used to make interior molded components and under-the-hood components that withstand high temperatures. These resins are used in producing highly durable exterior primers, clear coat paints, tire-cord adhesives, brake pads and fuel system components. Formaldehyde is also used for door and window insulation for modern airplanes.
Healthcare: Formaldehyde has a long history of safe use in manufacturing vaccines, anti-infective drugs and hard-gel capsules. It is used in vaccines to inactivate viruses such as Influenza so they don’t cause disease. Formaldehyde-based thermoplastics are also used in inhalers and epinephrine injectors.
The threat from potential new regulations
Unfortunately, the use of formaldehyde is under threat by flawed analysis found in a 2022 draft assessment by the Integrated Risk Information System (IRIS) program. IRIS, a program that has never been authorized by Congress, was initially created to support EPA's mission by identifying and characterizing human health effects that may result from exposure to chemicals. However, the IRIS program has a troubling history of being out of step with the best available science and methods, lacking transparency and being unresponsive to peer review and stakeholder recommendations. Members of the scientific community, including the National Academy of Sciences, have called attention to the IRIS program’s failure to use modern scientific approaches to draw conclusions regarding human health risk.
IRIS assessments are known to generate overly conservative values that have not fully evaluated the best available science, and have even proposed and finalized toxicity values below levels naturally produced by the human body or that are naturally occurring. Since IRIS assessments do not undergo a "reality check" to ensure their values make sense, they can lead to unnecessary public alarm and inaccurate risk management decisions. The 2022 draft IRIS assessment sets an exposure limit for formaldehyde that is actually below its natural background levels or levels that can be detected using the latest monitoring technology.
EPA is out of step with the scientific community and international regulatory bodies that have evaluated formaldehyde recently. While not considering the full body of scientific evidence, the 2022 draft IRIS assessment sets an "acceptable exposure limit" significantly lower (up to 4,000 times) than that set by the European Union, which incorporated studies published over the last 30 years in their recent assessment. If EPA uses the draft IRIS assessment to set new formaldehyde regulations employing such low exposure limits, the negative impact on vital industry sectors, plus the health and safety of critical food products, will send ripple effects across the U.S. economy.
Impacts of unnecessary over-regulation
Products based on formaldehyde technologies supported roughly 1 million jobs and over a half a trillion dollars in sales in 2021 alone. Overly restrictive regulation of formaldehyde that provides no additional public health benefit would not only jeopardize those jobs, but would also harm supply chains, affecting consumers, producers and workers in the construction, housing, wood products, agriculture, chemical, transportation, consumer products and energy industries.
Scientifically unjustified over-regulation of formaldehyde would also cost the U.S. food system billions of dollars. Formaldehyde helps protect against substantial disease-induced economic losses across animal agriculture. Even using formaldehyde, the cost due to disease already totals billions of dollars each year. Without formaldehyde’s critical applications, significantly greater losses could catastrophically damage U.S. farmers' livelihoods and the broader domestic economy. For example, if the U.S. saw outbreaks of African Swine Fever similar to those seen recently in China, it could decimate the U.S. pork industry — resulting in nearly $50 billion in losses to American’s farmers. Such an outbreak would create shortages, dramatically raising prices for consumers and straining the U.S. food system.
If you're concerned about the potential impact of restricting access to this vital material, learn more and find out how to engage at www.americanchemistry.com/formaldehyde.
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